Personal Data and Content Policy - OpenTouch Personal Cloud (“OTPC”)

This Personal Data and Content Policy, and related Data Privacy Notices specific to Services as the case may be, both supplementing the ALE International Data Privacy Policy to the extent relevant to the Services (together: “Policy”), provides information on why and how Your Personal Data (as defined below) and Content is managed by ALE International and its affiliates (“ALE”, “We” or “Us”) to deliver the Services to You.

In case of discrepancy between this Personal Data and Content Policy and ALE International Data Privacy Policy, this Personal Data and Content Policy shall prevail.

Your company decided to subscribe to OTPC Services through an ALE reseller (“Business Partner”) and You are a registered user of the OTPC Services. In this context, You and Your company choose to entrust Us with Your Personal Data and Content, and to authorize Us to collect, access, use, process, retain or disclose them according to this Policy.

Doing so, You and/or Your company, and the Business Partner are the ones who determine at Your own initiative the purposes and the means for processing Your Personal Data and Content, acting then as a data controller.

As a sub processor of Your Personal Data received from Your usage of Services, We recognize and respect Your legal rights and expectations in relation to privacy and protection of such data.

What is “Personal Data”?

Personal Data means information relating to an identified or identifiable natural person such as You, or information that is used to identify directly or indirectly such a natural person. Some examples of Personal Data are name, e-mail address, phone number, or information relating to Your usage of Services.

These Personal Data are split into 2 categories:

Account Personal Data: data relating to You which are provided by You, Your administrator or the Business Partner

Service Personal Data: data relating to Your usage of a Service

Your administrator and Your Business Partner have access to some of Your Personal Data, but not to Your Content, through PCS. More details may be found in the Data Privacy Notice for PCS.

What do we mean by Business Partner, Service Provider and Third Parties?

A Business Partner is an authorized reseller accredited by ALE International for the distribution of OTPC Services to companies such as Yours.

A Service Provider is any legal entity that delivers services to or on behalf of ALE International or an affiliate. Service Providers may access Your Personal Data to provide the Services to You. More details may be found in the Data Privacy Notice for the Services.

A Third Party is any natural or legal person, or any other body other than You, Your company, the Business Partner, Us, or Service Providers.

Our commitments to You

Transparency

When we do make it available for the corresponding Service, each Data Privacy Notice will further describe where, why and by whom Your Personal Data are being collected, used, retained, transmitted or otherwise processed.

Choices & consent

We will inform You of the choices You may have relating the processing of Your Personal Data and, when required, will ask You for Your consent.

Data access

You have the right to access to Your Personal Data to review, update, correct or delete it.

Account Personal Data: You will have the right to review Your Account Personal Data and make corrections or updates where applicable, and also to withdraw Your consent, by requesting the closure of Your OTPC Service account to Your administrator or Business Partner.

Service Personal Data: As the information stored in this specific category reports Your past usage of the OTPC Service, You may not change those data. However, You may report unauthorized usage of Your account to Your administrator or Business Partner.

For any question You may have on Your Personal Data, You may contact Your Business Partner who will provide You with all necessary information.

Proportionality

Only Personal Data relevant and useful for the purpose of delivering the Services to You, as described in each Data Privacy Notice, are collected. We will use such Personal Data only for the purpose(s) for which the data were collected, or for additional lawful and legitimate purposes for which consent has been obtained, when required.

Personal Data will be retained as long as necessary to fulfill the purpose(s) and according to the retention period(s) permitted by the applicable law.

Sharing information

We will share Your Personal Data only with the Business Partner and with Service Providers to carry out the OTPC Services to You. We may share Your Personal Data among affiliates of ALE International. We do not voluntarily disclose Your Personal Data or Content to Third Parties unless required by law, or under order from regulation Authorities.

Data protection

We use industry standard security protocols to protect Your Personal Data and Content in transit to and from Internet. This is commonly referred to as transport layer security protocol (“TLS”). However, Internet data transmissions, whether wired or wireless, cannot be guaranteed to be 100% secure, and as a result, We cannot ensure the security of information You, Your administrator or Your company’s Business Partner transmit to Us, beyond what is afforded by the aforementioned technology: in transmitting information, there is inherently a level of risk that You acknowledge You take.

Once We receive Your Personal Data and Content, we take commercially reasonable precautions to protect it on our servers, using a combination of administrative, physical and logical security safeguards:

Physical access to our data centers is strictly controlled, such as through electronic access control, or validation by human security personnel

Our networks are protected by security equipment and access control policies, such as through the use of firewalls or functionally equivalent technology

Our security program is periodically reviewed to determine whether additional or different security measures are required to respond to new security risks

We only provide information to employees and contractors who have a legitimate business need for such privileges, and revoke immediately this privilege when an employee and/or contractor no longer has a business need

Access to Your Personal Data, through PCS, is granted based on need to know / need to do as further described in the Data Privacy Notice for PCS

In the event, we have actual knowledge of a security system breach, we use commercially reasonable measures to contain such security breach and to prevent any further security breaches.

Data quality

We provide You, Your administrator and Your company’s Business Partner with access to Your Personal Data and the means to amend it, to ensure that the Personal Data we process is complete and relevant for the purpose(s) described in each Data Privacy Notice.

Cookies

A cookie is a piece of information, usually a small text file, that is generated by a web server and that is placed on Your computer or mobile device by a Service. A cookie file may contain information such as Your user ID that the website or service uses to remember the pages that You visit. The cookies on the Services are either set by Us, or by Service Providers.

You can refuse cookies by turning them off in the Your browser settings as explained here www.aboutcookies.org

If You block, turn off or otherwise reject cookies, Services may however not display properly. If You disable cookies from Your browser, You will not be able to use the Services that require Your authentication.

Our website www.opentouch.com has a public access. We use cookies for analytics purposes. These cookies allow us to get measures on:

Who visits this site

How visitors navigate on this site

How visitors arrive at the site (e.g. direct hit, via search engine)

What pages visitors are looking at

How long they stay on this site

Our objective is to better understand how visitors benefit from this site in order to optimize it and improve it.

Specific additional cookies may be mentioned in Data Privacy Notices.

Notification of changes

We may change from time to time this Policy. We will post the updated versions online with its applicable effective date.

Your acknowledgement

By subscribing to or using Services, You expressly consent to ALE International and its affiliates managing Your Personal Data and Content in accordance with this Policy. You acknowledge that You understand the purpose for which Your Personal Data is being collected, how it will be used, and how to contact the organization that is collecting and using Your Personal Data in order to exercise Your access rights.